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IN THE INCOME TAX APPELLATE TRIBUNAL “B” BENCH, MUMBAI BEFORE SHRI OM PRAKASH KANT, AM AND MS. KAVITHA RAJAGOPAL, JM ITA No.7044/Mum/2025 M/s. National Payments Corporation CIT (Exemptions), of India, Room No.601, 6^th Floor, 1001A, B-Wing, 10^th Floor, Cumballa Hill MTNL TE Building, The Capital, Plot No.C-70 Vs. Peddar Road, Bandra Kurla Complex, Bandra, Dr. Gopalrao Deshmukh Marg, Mumbai – 400 051 Cumballa Hill, Mumbai – 400 026 PAN: AACCN9852G (Appellant) : (Respondent Assessee by : Shri Niraj Sheth, AR Ms. Niyati Parikh, AR Respondent by : Shri Vijaykumar Soni, CIT DR Date of Hearing : 18.02.2026 Date of Pronouncement : 25.03.2026

O R D E R

Per Kavitha Rajagopal, JM:

This appeal is filed by the assessee, challenging the order of the Learned Commissioner of Income Tax (Exemptions) [‘Ld. CIT(E)’ for short], passed u/s. 12AB of the Income Tax Act, 1961 (‘the Act').

2. The assessee has raised the following grounds of appeal:

“1. The learned Commissioner of Income tax (Exemptions) ("Ld. CIT (E)") erred in invoking provision of section 12AB(4) of the Income Tax Act, 1961 ("the Act") without satisfaction of the jurisdictional pre-conditions necessary for invoking such power.

2. Ld.